Common Violations Identified During Annual Respiratory Protection Program Reviews

January 5, 2015 – It’s often said that the devil is in the details, and that could not be truer than when it comes to the requirements of some of OSHA’s comprehensive health and safety standards. In fact, there are several OSHA standards that actually require affected employers to conduct annual program reviews, including the OSHA respiratory protection standard (see requirement at 1910.134(l)(1) and (2). Therefore, I am going to start off this New Year by outlining the problems most commonly identified when I assist employers with their annual respiratory protection program reviews.

Facial Hair – OSHA standard 1910.134(g)(1)(i)(A) states that employers “shall not permit respirators with tight-fitting face-pieces to be worn by employees who have facial hair that comes between the sealing surface of the face-piece and the face . . .”. Unfortunately, this language is very subjective, and employers often tell me they are really not sure how often their workers are required to shave, since some employees who shave in the morning can grow a five o’clock shadow before lunchtime, while others still have a relatively smooth face a couple of days after shaving. Fortunately, OSHA gives us guidance in their compliance directive (CPL 02-00-158), titled “Inspection Procedures for the Respiratory Protection Standard”, which was updated in June of 2014. On page 27 of that directive, OSHA states that the compliance officer “should be alert for the presence of facial hair (more than one day's growth) that comes between the sealing surface of the respirator and the face . . . “. It has been my experience that OSHA interprets “one day’s growth” as meaning no more than 24 hours growth. So basically, if the respirator user’s shift ends at 5 pm today, he must have shaved at some time after 5 pm on the previous day.

Fit Test for ALL Tight-fitting Respirators – OSHA standard 1910.134(f)(2) requires the employer to “ensure that an employee using a tight-fitting face-piece respirator is fit tested prior to initial use of the respirator, whenever a different respirator face-piece (size, style, model or make) is used, and at least annually thereafter.” What I find when evaluating records is that in many cases there is one fit test record on file for a particular employee, and it covers the one type of tight-fitting face-piece respirator that the worker wears while performing their regular day-to-day tasks. But in many cases, the same employee is also designated as a member of the company’s emergency response team and/or confined space rescue team, which may require them to use a different type of tight-fitting face-piece respirator (such as an SCBA), and there is not an additional fit test record on file. It is important that each and every tight-fitting face-piece respirator that a worker may be required to wear be fit tested for that user, and a fit test record on file for each type worn. And remember, this requirement applies to ALL tight-fitting face-piece respirators regardless of whether they are the positive or negative pressure type.

Medical Determination for EACH Type Respirator – OSHA standard 1910.134(e)(6)(i) requires employers to obtain a written recommendation from a designated physician or other licensed health care professional (PLHCP) regarding each employee's ability to use their respirator. However, I commonly find the same basic issue with this requirement as I do with the previous paragraph addressing fit testing; that is, records on file show that the employee was evaluated for one type of respirator (usually the one they use on a day-to-day basis), but not for one they may use on special occasions only (such as for emergency response activities). Some respirators (such as heavy SCBA’s equipped with air tanks) worn in an emergency situation can place a much greater physical burden on a worker than a cartridge-type respirator used for normal day-to-day activities. Therefore, it is important for the PLHCP to know each type of respirator a worker is subject to using and all tasks they may perform while wearing it, as well as all other required info (such as additional PPE worn, exertion level, temperature extremes . . .) for each situation. And the written release(s) provided by the PLHCP must apply to each and every type of respirator the employee has been approved to use.

Calibration of CO Monitors – Employees using supplied air respirators that are fed breathing air generated by oil lubricated compressors must be protected against the potential of carbon monoxide being present in unsafe levels. One way to meet this requirement is the installation of an in-line carbon monoxide (CO) monitor with alarm, as allowed in 1910.134(i)(7). However, I commonly find that the CO monitoring equipment is not maintained per the manufacturer’s requirements. While each manufacturer’s requirements differ, most of them require the application of a calibration gas to check the CO sensor and alarm, usually on a monthly basis. Without following the manufacturer’s required maintenance and calibration requirements, the CO sensor may not function as needed to protect the worker. And sometimes I find employers who are performing the calibrations, but they are using a cylinder of calibration gas that has expired. So pay close attention to the expiration date on those cylinders. OSHA citations have been issued many times to employers who do not maintain and calibrate CO monitoring equipment per the manufacturer’s instructions.

Respirator Cartridge Change-out Schedules – 1910.134(d)(3)(iii)(B)(2) is probably the most overlooked (or misunderstood) requirement appearing in the OSHA respiratory protection standard, and it has to do with the development of a change-out schedule for canisters and cartridges on air purifying respirators used to protect workers from gases and vapors. The “old” OSHA respiratory protection standard allowed workers to count on smell or taste to let them know when their canisters and cartridges were loaded and needed to be changed (a condition known as break-through). However, the revised (1998) OSHA respiratory protection standard specifically prohibits this practice as the primary method for determining when to change canisters and cartridges. Nor can employers select some arbitrary time period, like once every day, to change canisters and cartridges, because even this may not be adequate to protect the respirator user.

Instead, OSHA requires the development of a canister and cartridge change-out schedule based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life, unless they are equipped with an end-of-service-life indicator (ESLI). This requires the employer to gather data, such as an estimate of the concentration(s) of contaminant(s) present in the workers’ breathing zone, temperature and humidity extremes, exertion levels, and PPE worn for each area where air purifying respirators are used to protect against gases and vapors. This, in turn, allows the employer to calculate a useful life for each type canister or cartridge being used so they can implement procedures to ensure workers change their canisters and cartridges before their useful life has been exceeded. Cartridge manufacturers provide formulas and instructions to help employers calculate change-out schedules, as does Appendix B of the OSHA CPL for inspecting respiratory protection programs. However, you may want to consider employing the services of an industrial hygienist to assist you in this effort.

So there is my list of common problems identified during annual respiratory protection program reviews. Have you had similar experiences? Perhaps you have some additional information about these issues that you’d like to share. If you do, or if you’d like to make a general comment about this topic, please click here and you will be directed to the “Comments” box for this blog post. And last but not least, I would like to encourage you to Share this Blog post with others in your Network who might benefit from reading this information.

ABOUT THE AUTHOR:

Curtis Chambers is a Certified Safety Professional (CSP) and holds a Master of Science degree in Occupational Safety and Health. He has held numerous leadership positions managing and evaluating health and safety programs and providing training on workplace safety and health topics at various public organizations and private corporations. Mr. Chambers is currently the President of OSHA Training Services Inc. Visit their website at www.oshatraining.com.

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